Notebook privacy policy

This privacy policy for SMART Notebook® (“Notebook Privacy Policy”) desktop software forms part of the Terms agreed upon between you and SMART. This policy explains how SMART works with you to protect your information and privacy when using Notebook.

By using Notebook you are consenting to SMART's collection, retention, use and disclosure of certain information as necessary to provide Notebook to you. If you do not agree, you must not use Notebook.

Automatic Error Reporting: If an SLS application encounters an issue, the application automatically sends the following anonymous information to SMART’s sub-processor Sentry.io (located in the United States):

  • Lesson ID (no PII)
  • User ID and Session IDs (hashed and salted to maintain anonymity)
  • request header (application and version, platform, operating system, browser, language, date and time)
  • bread crumbs (last pages visited and links clicked)

Optional User Error Reporting: After automatic error reporting is complete, users are given the option to provide their name, email address, and additional information about the error. Users are also asked if they wish SMART to follow up with them. This optional personal information is stored in Salesforce (located in the United States) and shared with our customer support team.

It is important to remember that customers and users are two distinct groups:

Typically, a customer is an organization (e.g., district, school, company) and not a personally identifiable individual. The identifiable information we require is from the organizational purchaser for transactional purposes. The customer should not be providing SMART with personally identifiable information unless permissible by law and the customer’s policies.

Our users (e.g., teachers using Notebook) are generally not the ones who purchased or setup the account and users are only accessing Notebook because the customer’s administrator has granted them access. As such, SMART’s exposure to personally identifiable information only comes from how the customer operates when providing e-mail addresses and names of users to SMART and from user created Content. If you have a concern as a user about your PII you must demand the customer provide only non-identifiable information to SMART and you as a user must only create Content with no PII in it.

Still concerned?

There is no student sign-in for Notebook (Lumio by SMART) and teachers can use SMART Notebook® Basic without signing-in.

Teachers can choose to share their created content in a number of ways that do not require students to sign-in.

You own your data and SMART does not sell it or use it for advertisement purposes. We use your data to provide Notebook to you. Data portability and deletion is managed by the customer who can request its deletion at any time.

Optional sign-in and therefore account security, is handled by the world class providers Google and Microsoft. Both providers support two-step (dual) authentication and enforce strong password creation. Both providers state you can use their services in compliance with GDPR.

User data is encrypted at rest and in-transit.

What about GDPR, CCPA, and FERPA?

User created Content is not a student or educational record, transcript, gradebook, health or directory information. Notebook is not a learning management system (LMS).

SMART supports the European Union General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and numerous other laws including the Family Educational Rights and Privacy Act (FERPA). SMART is committed to helping our customers work under these and other stringent regulations and we continue to add in-region solutions. We currently offer American and European data storage for user created Content and we are satisfied our out-of-region user data processors provide appropriate safeguards for the data they handle.

At this time, our e-commerce SLS store is only available for North American purchasers but you may always purchase from your regional SMART authorized reseller. For European customers please note, Canada benefits from a European Commission adequacy decision, the effect of which is that data can flow from the EU (and Norway, Liechtenstein and Iceland) to Canada without any further safeguards being necessary. In other words, transfers to Canada are treated as intra-EU transmissions of data.

Remember, SMART only receives information because you provide it; you are the data controller. In this way, customers and users are obligated to comply with their local laws and are responsible for any obligations they owe to their users with respect to their personally identifiable information.


PRODUCT USER DATA COLLECTED AND PROCESSED

This section outlines what data is collected, used, and disclosed from the two types of Notebook users:

  • Notebook Basic Users (not signed-in, no sharing)
  • Signed-In Notebook Users

Deletion requests for users’ data is controlled by the customer. If you are accessing Notebook through your school, you should make your deletion request to them. If you are a minor, SMART reserves the right to provide access to your account to your parents, guardian, or other authorized adult (teacher, school administrator) or, if required by law.

The term “identifiable” used in the below charts does not necessarily mean personally identifiable information.

 SMART Notebook® Basic Users (not signed-in; no online sharing)

The basic version is free software designed for use with a SMART Board® interactive display. It comes with many features that you can use to create and edit lessons. You can use it without an Internet connection. A watermark appears on each lesson page if the computer on which you are running the basic version is not connected to a SMART Board. Typically, SMART Notebook users are using it with a SMART Board®.

Where Who Role Data & Purpose Type
SMART Technologies ULC Manufacturer Required. If used offline no information is transmitted to SMART or any other party for that matter. When connected to the Internet we collect anonymous analytics and optional (opted-in) crash report data. Anonymous
Mixpanel, Inc. Monitoring Required for product improvement and service monitoring. Mixpanel allows us to analyze how our anonymous basic free users interact with Notebook. It is designed to identify trends, understand common aggregated usage behavior, and helps us make better decisions on how to improve the usability and features of our product. Anonymous
Google, LLC Monitoring Required for product improvement and service monitoring. Google Analytics allows us to analyze how our anonymous basic free users interact with Notebook. It is designed to identify trends, understand common aggregated usage behavior, and helps us make better decisions on how to improve the usability and features of our product. Anonymous

 SIGNED-IN NOTEBOOK USERS (teachers)

A subscription to SMART Learning Suite gives you access to all of SMART Notebook’s features. Without a subscription, you can still get access to the basic version of SMART Notebook (see above). The sharing of user created Content with students over the Internet is done via Lumio.

Where Who Role Data & Purpose Type
SMART Technologies ULC Manufacturer Required account details: display name, name, email, public profile picture. language preference. Required account profile settings: opt-ins, user type, location.
We also offer an optional opt-in to SMART’s Customer Experience Program that collects and transmits additional information about the computing environment and the frequency with which our software and its features are used. You can turn off the Customer Experience Program at any time. Sending anonymous crash data is optional.
Identifiable
Microsoft, Inc. Product Functionality Required if you use Microsoft as your single-sign-on (SSO) provider to access Notebook. Microsoft provides SMART with required account details. Identifiable
Google LLC Product Functionality Required if you use Google as your single-sign-on (SSO) provider to access Notebook. Microsoft provides SMART with required account details. Identifiable
, Amazon Web Services, Inc. Product Functionality Required for storage. We offer both an American and European data storage option. Identifiable
,, Firebase, Google LLC Product Functionality Required for basic functionality (Firebase is a Backend-as-a-Service (BaaS) cloud-computing solution we use for real time (temporary) automated computer processing.) Identifiable
Mixpanel, Inc. Monitoring Required for product improvement and service monitoring. Mixpanel allows us to analyze how our de-identified users interact with Notebook.
It is designed to identify trends, understand common aggregated usage behavior, and helps us make better decisions on how to improve the usability and features of our product. This data is also used to track how long it takes our servers to complete actions like open files, which helps us measure service health and up/downtime.
Pseudonymized
Google, LLC Monitoring Required for product improvement and service monitoring. Google Analytics allows us to analyze how our anonymous basic free users interact with Notebook. It is designed to identify trends, understand common aggregated usage behavior, and helps us make better decisions on how to improve the usability and features of our product. Pseudonymized
Third-party content and activity providers Optional Product Functionality Optional content or activity a teacher may add to a lesson such as a YouTube or other embedded content a user voluntarily adds. We cannot control what data a third party directly collects via the content when a teacher or student decides to include it in a lesson. For premium content that SMART provides however, we only report anonymous usage to the third-party publisher. Identifiable

CUSTOMER DATA COLLECTED AND PROCESSED

This section outlines what data is collected, processed, and disclosed from customers (purchasers, prospects, and SMART’s authorized channel partners). You can request, through our Customer Support, data and account deletion at any time, but we must retain all data relevant to purchases and financial transactions until it is no longer required by applicable law. The term “identifiable” used in the below chart does not necessarily mean personally identifiable information.

The customer must install SMART Notebook desktop software on the applicable computers and give teachers access to the software using one of the two activation methods (support pages do not form part of this Notebook Privacy Policy or Terms; they are provided for convenience only).

Where Who Role Data & Purpose Type
Reseller & SMART’s Regional Office Seller Required contact information: organization name, e-mail, title, phone, address. Required order information: product, quantity, price and tax, delivery. Ask your local regional reseller about their privacy policies. Identifiable
SMART Technologies ULC Manufacturer Required account information: organization name, e-mail, title, phone, address, reseller, current subscriptions. Required order information: product, quantity, price and tax, delivery. Required admin portal information for license provisioning: licenses and activations, teachers’, and admins’ first and last names (can provide non-PII version to comply with GDPR) and e-mail address, and class names (can be non-PII version to comply with GDPR). Identifiable
Blue Ocean Contact Centers, Inc. Support Optional. Blue Ocean is a subcontractor providing live (telephone, e-mail, and web) support. Information collected includes organization name, caller name (can use company title only if preferred for GDPR reasons), e-mail (can provide non-PII version to comply with GDPR), title, phone, address and a description of the issue and any shared details to help solve the problem. Calls are recorded. Identifiable
Amazon Web Services, Inc. Processing, Back-Office Required for product infrastructure including the hosting of support call recordings. Identifiable
Google, LLC. Processing, Back-Office. Optional. Only used for processing of support forms. Google Forms are used when a purchaser is engaged with our Field Services (i.e., onsite support). Identifiable
Microsoft, Inc. Processing, Back-Office Required for our enterprise resource planning (ERP) system, which is software to manage the day-to-day business activities such as accounting, procurement, project management and supply chain operations, as well as our e-mail, PowerBI® (data visitation) and SharePoint® (document management), as well as all the other standard Microsoft Office software titles, like Word, Excel, etc. Identifiable
BigCommerce, Inc. Ordering Optional. Only used when a customer purchases through our e-commerce store: customer name, e-mail, title, phone, address, product, or service purchased and whether payment is received. Identifiable
, Stripe, Inc. and Stripe Payments Europe, Ltd. Ordering Optional. Only used when a customer purchases through our e-commerce store using a credit card: customer name, e-mail, title, phone, address, product, or service purchased, credit card details. Residents of the European Economic Area (EEA), the UK and Switzerland. The entity responsible for the collection and processing of credit card personal data for residents of the EEA, the UK and Switzerland is Stripe Payments Europe, Ltd., a company incorporated in Ireland and with offices at 1 Grand Canal Street Lower, Grand Canal Dock, Dublin. To exercise your rights, the Data Protection Officer may be contacted via dpo@stripe.com. Identifiable
Salesforce.com, Inc Ordering, Marketing, Channel Support Required order information (product, quantity, price and tax, delivery). Required for our customer relationship management (CRM). Required to allow our authorized distributors and resellers to work together with SMART. Basic customer and purchase information is shared between SMART and its authorized distributors and resellers. Identifiable
HubSpot, Inc. Marketing Optional. We use HubSpot, which is a customer relationship management (CRM), for individuals that have expressly opted in to receive certain communications, such as marketing, training, news, and offers from us. Identifiable
Mixpanel, Inc. Monitoring Required for product improvement and service monitoring. Mixpanel allows us to analyze how our de-identified users interact with Notebook. It is designed to identify trends, understand common aggregated usage behavior, and helps us make better decisions on how to improve the usability and features of our product. This data is also used to track how long it takes our servers to complete actions like open files, which helps us measure service health and up/downtime. Pseudonymized
Google, LLC Monitoring Required for product improvement and service monitoring. Google Analytics allows us to analyze how our anonymous basic free users interact with Notebook. It is designed to identify trends, understand common aggregated usage behavior, and helps us make better decisions on how to improve the usability and features of our product. Pseudonymized
Gainsight, Inc. Marketing Applicable only to USA Customers. We use Gainsight, which is a customer relationship management (CRM) tool, for e-mail (name, e-mail address, company information) marketing to individuals and organizations. Identifiable

THIRD PARTIES

To the extent functionality is not directly provided or managed by SMART, such as single-sign-on (SSO) via Google and Microsoft, YouTube®, etc., you agree it is your responsibility to review and accept these third-party service providers’ terms and privacy policies. Links to their policies have been provided.


COOKIES

SMART and some of its processors use cookies to provide Notebook to you. Cookies are small files that are placed on your computer or device. Most web browsers allow some control over cookies through the browser settings. Blocking all cookies will, however, have a negative impact upon the usability of Notebook. Thus, you may prefer to accept cookies and then delete them later or upon exiting your session.

Who Cookie Purpose
SMART id.smarttech-prod.com
_ga
_gid
_ids
_ids_legacy
_ssos
_ssos_legacy
Required for providing navigation, log-in status, and user identification for the purpose of providing Lumio to the user, including the proper linking of user created Content.
Microsoft login.microsoftonline.com
AADSSO
CCState
ESTSAUTH
ESTSAUTHLIGHT
ESTSAUTHPERSISTENT
ESTSSC
SignInStateCookie
brcap
buid
ch
clrc
esctx
fpc
stsservicecookie
x-ms-gateway-slice
login.live.com
MSPRequ
uaid
Required for providing single-sign-on functionality and identification of the user for the purpose of providing Lumio to the user. These cookies are installed by Microsoft and SMART has no control over what Microsoft does with the information. Click here for additional information on Microsoft’s cookies.
Google LLC accounts.google.com
ACCOUNT_CHOOSER
LSID
__Host-3PLSID
__Host-GAPS
user_id
google.ca
APISID
HSID
NID
SAPISID
SID
SSID
__Secure-3PAPISID
__Secure-3PSID
google.com
APISID
HSID
NID
SAPISID
SID
SIDCC
SSID
__Secure-3PAPISID
__Secure-3PSID
__Secure-3PSIDCC
youtube.com
APISID
HSID
SAPISID
SID
SSID
__Secure-3PAPISID
__Secure-3PSID
Required for providing single-sign-on functionality and identification of the user for the purpose of providing Lumio to the user. YouTube cookies are installed during sign-on and support additional functionality (adding videos) within Lumio. These cookies are installed by Google and SMART has no control over what Google does with the information. Click here for additional information on Google’s cookies.
Google LLC _utma This cookie is typically written to your browser upon the first visit to www.smarttech.com and our admin portal site. If the cookie has been deleted by the browser operator, and the browser subsequently visits our site, a new __utma cookie is written with a different unique ID. This cookie is used to determine unique visitors to our site and it is updated with each page view. Additionally, this cookie is provided with a unique ID that Google Analytics uses to ensure both the validity and accessibility of the cookie as an extra security measure. This cookie is a persistent cookie with a lifespan of 2 years from set/update.
Google LLC _utmb This cookie is used to establish and continue a visitor session with our admin portal site. When a visitor views a page on our site, the Google Analytics code attempts to update this cookie. If it does not find the cookie, a new one is written and a new session is established. Each time a visitor visits a different page on our site this cookie is updated and will expire in 30 minutes, thus, continuing a single session for as long as visitor activity continues within 30-minute intervals. This cookie is a session cookie with a lifespan of 30 minutes from set/update.
Google LLC _utmc Historically, this cookie operated in conjunction with the __utmb cookie to determine whether to establish a new session for the visitor. For backwards compatibility purposes with sites still using the urchin.js tracking code, this cookie will continue to be written and will expire when the user exits the browser. This cookie may or may not be set and is a session cookie with a lifespan of the browser session.
Google LLC _utmz This cookie stores the type of referral used by the visitor to reach our site, whether via a direct method, a referring link, a website search, or a campaign such as an ad or an email link. It is used to calculate search engine traffic, ad campaigns and page navigation within our site. The cookie is updated with each page view to our site. This cookie is a persistent cookie with a lifespan of 6 months from set/update.
Identity Client library software_portal When administrator signs in from SMART’s admin portal, this cookie is set to remember the authorization information for the current signed in session. The cookie will be refreshed automatically to keep the session alive. This cookie is set by SMART and is a persistent cookie with a lifespan of 365 days. The content of the cookie is the encrypted id access token and id refresh token
Language Cookie website#lang, support#lang, training#lang This cookie saves your language selection for our website.
Sitecore SC_ANALYTICS_GLOBAL_COOKIE This cookie is associated with our Sitecore content management system and is used for web analytics to identify repeat visits by unique users.
Smart ID SMARTId, SMARTIdState, SMARTIdReturnUrl These cookies are written to your browser when you sign-in to SMART ID. Signing out of your SMART ID deletes this cookie. These cookies store encrypted authentication information that only our servers can decrypt. This cookie is persistent and lasts for several hours.

HAVE A QUESTION FOR US? We would love to hear from you:
SMART Technologies ULC
Attention: Legal Department
Suite 600, 214-11 Ave SW
Calgary, AB T2R 0K1
CANADA
+1.403.245.0333
SMART’s Privacy Office
privacy@smarttech.com

Last Updated: February 1, 2021